Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy

Domain: rirabet.net | Brand: rira bet

Last Updated: 22 August 2022 (periodically reviewed and improved)

This AML & CTF Policy sets out the minimum standards and control framework adopted across rira bet to prevent its services from being used for money laundering, terrorist financing, fraud, or any other financial crime. The policy is designed to align with widely recognized global principles, including risk-based supervision, customer due diligence, ongoing monitoring, suspicious activity reporting, record retention, and data-protection by design. The measures described herein apply to all users, payment channels, employees, contractors, and technology partners that interact with rirabet.net.

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1) Purpose, Scope, and Regulatory Alignment

The primary objective of this policy is to deter and detect the placement, layering, and integration of illicit funds through gaming-adjacent financial flows. The policy covers account creation, deposits, withdrawals, internal transfers, bonus credits, refunds, chargebacks, and exceptional manual adjustments. While rira bet does not position itself as a financial institution, it implements controls that are consistent with international AML/CTF expectations to protect customers and the integrity of its platforms.

• Geographic reach: All jurisdictions in which users access rirabet.net, subject to geoblocking and local restrictions.
• Regulatory alignment (non-exhaustive, informative only): EU AML principles (e.g., Directive 2015/849/AMLD4 and successor measures), transfer-of-funds information standards (EU 2015/847), domestic cash-use limitations where applicable, and generally accepted risk-based compliance practices.
• Legal disclaimer: Users are responsible for ensuring that access to products or content complies with the laws of their country of residence. Where national law prohibits gambling or imposes stricter KYC/AML rules, those local rules prevail and access may be restricted or denied.

2) Definition of Money Laundering and Terrorist Financing

Money Laundering (ML) refers to any act intended to conceal the illicit origin of assets or to help any person evade legal consequences for criminal conduct. It typically includes conversion, transfer, concealment, acquisition, possession, or use of assets derived from crime, as well as participation, aiding, abetting, or facilitation of these acts. Terrorist Financing (TF) concerns the collection or provision of funds with the intent or knowledge that they will be used to carry out terrorist acts, regardless of whether the funds are from lawful or unlawful sources.

3) Governance and Accountability

• Ultimate Oversight: The senior management of the operating entity has ultimate responsibility for AML/CTF compliance and the effectiveness of internal controls.
• AML Compliance Officer (AMLCO): rira bet appoints an AMLCO with direct access to senior management. The AMLCO designs, implements, and continuously improves the AML framework, approves major policy updates, and supervises investigations.
• Three Lines of Defense: (1) Operational teams and automated controls; (2) the AMLCO and compliance function; (3) internal audit or independent assurance, which tests control design and operating effectiveness at defined intervals.

4) Risk-Based Approach (RBA)

rira bet applies a risk-based approach to allocate controls where they are most needed. Risks are assessed across customers, products, channels, counterparties, and geographies. Elevated-risk situations trigger enhanced measures.

Risk Tier	Illustrative Characteristics	Controls (Minimum)
Low	Consistent behavior, domestic cards/banks, stable IP/device, modest volumes	Standard KYC, sanctions/PEP screening, ongoing automated monitoring
Medium	Cross-border activity, frequent method changes, increased volumes	Lower transaction thresholds for EDD, tighter velocity limits, documentary PoA
High	Sanctioned or high-risk geographies, crypto-fiat cycling, mismatched ownership	EDD with source-of-funds/wealth, manual review, potential blocking or exit

5) Customer Due Diligence (CDD) and KYC Standards

Formal identification is required before enabling sensitive account functions. CDD information must be true, accurate, and kept up to date. Users agree to cooperate with verification promptly; failure to do so may result in account restrictions.

5.1 Standard Verification (Step 1)

• When required: Prior to withdrawals and whenever account risk dictates.
• Data points: Legal first and last name, date of birth, country of residence, gender, and full residential address.
• Screening: Automated checks against sanctions and PEP watchlists; age checks to confirm 18+ eligibility.

5.2 Document Verification (Step 2)

• Trigger thresholds: Single or cumulative deposits or withdrawals over 2,000 USD (or currency equivalent), or as adjusted by the AMLCO per the RBA.
• Required: Government-issued photo ID (passport, national ID, or driving license). A second selfie image may be requested. Users may mask nonessential fields, but name, photo, DOB, nationality, gender, and document edges must remain clear and fully visible.
• Electronic validation: Cross-checks using reputable data providers. If e-checks fail, a Proof of Address (PoA) dated within the last 90 days is required (utility bill, bank statement, or a government letter).

5.3 Source of Funds/Wealth (Step 3)

• Trigger thresholds: Deposits or withdrawals over 5,000 USD (or equivalent), or person-to-person transfers over 3,000 USD, or other activity patterns indicating elevated risk.
• Acceptable evidence: Payslips or employment contracts; audited business financials or recent tax returns; inheritance or trust documents; investment statements; annotated bank statements showing provenance and flow of funds.
• Outcome: Until EDD is complete, impacted transactions may be temporarily held. Noncooperation or inconsistency can result in rejection or account closure.

6) Prohibited and Restricted Activity

• Use of stolen, forged, or third-party payment instruments.
• Cycling funds without genuine gameplay intention (rapid deposit-withdraw patterns).
• Use of VPN or anonymizers to bypass geoblocking or regional restrictions.
• Structuring transactions to avoid thresholds or controls.
• Any conduct that contravenes sanctions, export controls, or local gambling laws.

7) Geoblocking, Sanctions, and PEPs

Access may be geoblocked for jurisdictions identified as high-risk or where local frameworks prohibit access to the underlying content. All users are screened against sanctions lists and politically exposed person (PEP) databases. Matches and potential matches are reviewed under a documented false-positive methodology. Confirmed hits lead to blocking or account exit, and where required, reporting to competent authorities.

8) Payment Methods and Method-of-Return Rule

• Ownership match: The name on the payment account must match the verified account holder. rira bet may reject or reverse transactions that fail this test.
• Return to source: Withdrawals are, up to the amount of net deposits, returned to the original funding method to reduce ML/TF risk. Alternative routes require AMLCO approval and documentary substantiation.
• Card and bank checks: Additional micro-verification steps (e.g., micro-deposits, descriptors, card token checks) may be used to verify control of the instrument.

9) Ongoing Monitoring and Anomaly Detection

Customer behavior and transactions are monitored on a continuous basis using automated systems with manual oversight. Alerts are generated for unusual patterns, including:

• Deposit/withdraw cycles without proportionate gaming activity or with abnormal win-loss ratios.
• Frequent payment method changes, mismatched names, or country inconsistencies.
• Device, IP, or geolocation anomalies; high-risk time-of-day patterns.
• Use of multiple accounts or attempted account takeovers.

Alerts are triaged, investigated, and dispositioned. Where warranted, the AMLCO may request additional information, freeze funds, decline transactions, or offboard the user.

10) Suspicious Activity Reporting (SAR)

Where transactions appear unusual, lack apparent lawful purpose, or conflict with the user’s stated profile, the AML team will assess whether a Suspicious Activity Report (SAR) to a competent Financial Intelligence Unit (FIU) is required. Employees must escalate suspected cases immediately and maintain confidentiality in accordance with “tipping-off” prohibitions.

11) Thresholds and Velocity Limits

The AMLCO may impose dynamic thresholds at the user, cohort, market, or method level. Examples include daily, weekly, or monthly caps on deposits and withdrawals; cooling-off periods after significant wins or losses; and holds pending KYC/EDD outcomes. Thresholds may be lowered for medium/high-risk scenarios or raised once a user demonstrates consistent, low-risk behavior.

12) Data Protection and Privacy

• Data minimization: Only data necessary for AML/KYC and platform security is collected.
• Security: Data is encrypted in transit and at rest; access is granted on a lerirabetnet-privilege basis; security events are logged and periodically reviewed.
• Retention: Identification and transactional records are retained for at least 10 years after account closure or last transaction, unless a longer period is required by law.
• Sharing: Data is not sold. It may be shared with competent authorities when required by law or to prevent financial crime.

13) Recordkeeping

rira bet maintains complete, accurate, and retrievable records of KYC data, screening outcomes, alerts, investigations, SAR decisions, transaction logs, IP/device telemetry, and staff AML training. Records support regulator inquiries, audits, and law-enforcement requests.

14) Training and Awareness

• Induction: All new starters with access to financial processes complete AML/CTF training before handling customer activity.
• Annual refreshers: Role-based modules tailored to operational and risk functions, including case studies and typologies.
• Assessments: Staff must pass periodic knowledge checks; additional coaching is provided where gaps are identified.

15) Independent Testing and Continuous Improvement

Internal audit or an independent reviewer periodically assesses the AML framework against policy requirements and risk-based expectations. Findings are tracked to remediation with clear owners and timelines. The AMLCO conducts thematic reviews after major incidents or regulatory changes.

16) Policy Updates and Change Control

• Substantive changes to thresholds, verification standards, screening vendors, or reporting lines require AMLCO sign-off and senior-management approval.
• Users may be notified of material changes that affect how their personal data is processed or how withdrawals are handled.

17) User Responsibilities

• Provide accurate, complete KYC information, promptly respond to EDD requests, and keep contact details current.
• Use only payment instruments registered in your own name and under your control.
• Comply with your local laws. If gambling is prohibited or restricted in your location, do not attempt to access or use related services.

18) Examples of Acceptable Source-of-Funds Evidence

• Employment: Recent payslips and employer letter with contact details.
• Self-employment: Tax returns, audited financial statements, or accountant’s certification.
• Investments: Broker statements, dividend vouchers, or proof of asset sale.
• Inheritance/Gifts: Probate documents or notarized declarations, accompanied by bank statements showing receipt.

19) Frequently Applied Operational Rules

• Cooling-off upon alerts: Transactions may be queued during review; gameplay access may be limited in high-risk cases.
• Method consistency: Withdrawals are routed back to the original method where possible, up to net deposits.
• Multiple accounts: Prohibited. Detected linkages lead to consolidation, blocking, or exit.

20) Enterprise-Wide Risk Assessment (EWRA)

At least annually, rira bet completes an EWRA that evaluates inherent and residual AML/CTF risks across products, user segments, payment rails, delivery channels, geographies, and emerging typologies (including cyber-enabled fraud and account takeover). Control enhancements and budget prioritization follow from the EWRA outcomes.

21) Contact

Questions about this AML & CTF Policy, data handling, or verification requests can be addressed through the official support channels listed on rirabet.net. Do not share sensitive documents over unsecured channels. rira bet may request transmission via a secure portal or encrypted email solution.

22) Glossary (Selected)

• AMLCO: Anti-Money Laundering Compliance Officer, responsible for AML governance.
• CDD/KYC: Customer Due Diligence/Know-Your-Customer identification and verification activities.
• EDD: Enhanced Due Diligence, deeper checks for higher-risk cases.
• PEP: Politically Exposed Person, including family and close associates.
• SAR: Suspicious Activity Report to a competent FIU.

Important Note

This policy is intended to reflect rira bet’s commitment to a robust AML/CTF posture. It does not create third-party rights and may be amended at any time to address new risks, regulatory developments, or operational improvements. Where there is a conflict between this policy and mandatory local law, the latter prevails and access may be denied to ensure compliance.